British Energy Generation Ltd Hartlepool Power Station report - Q3 2009

Local community liaison council quarterly report for 1 July to 30 September 2009

Inspections
Routine matters
Non routine matters
Regulatory activity

Foreword

This report is issued as part of the Health and Safety Executive's commitment to make information about inspection and regulatory activities relating to the above site available to the public. It is for distribution to members of the Hartlepool Power Station Local Community Liaison Council and covers activities associated with the regulation of safety at Hartlepool Power Station. These reports are distributed quarterly and are also available on the HSE's web site at http://www.hse.gov.uk/nuclear/llc/index.htm. Site inspectors of HM Nuclear Installations Inspectorate usually attend LCLC meetings and will respond to questions raised there by members of the LCLC.

Nuclear Safety Directorate
Health and Safety Executive
Redgrave Court
Merton Road
Bootle
Merseyside
L20 7HS

Inspections

The Nuclear Installations Inspectorate (NII) Site Inspector made inspections at Hartlepool Power Station on the following dates during the quarter:

14 - 16 July 2009
30 July 2009
25 - 27 August 2009
8 - 9 September 2009
14 September 2009

On 9 September a small NII team led by the Site Inspector witnessed a repeat emergency exercise following the Level 1 emergency exercise held in April where a number of areas for improvement were identified.

Routine matters

Inspections at Site:Inspections are undertaken at site as part of the process for monitoring compliance with:

the conditions attached by HSE/NII to the nuclear site licence;
the Health and Safety at Work etc Act (HSWA) 1974 and
regulations made under the HSWA for example the Ionising Radiations Regulations 1999 and the Management of Health and Safety at Work Regulations 1999.

This entails monitoring licensee’s actions on the site in relation to incidents, operations, maintenance, projects, modifications, safety case changes and any other matters which may affect safety. The licensees/operators are required to make and implement adequate arrangements under the conditions attached to the licence in order to ensure legal compliance. Inspections seek to judge both the adequacy of these arrangements and their implementation. In this period routine inspections of Hartlepool Power Station covered:

Management of radioactive waste on site and the waste handling and dispatch facilities
Emergency Preparedness - The station provided a second demonstration of its emergency arrangements to an NII team following the level 1 exercise in April which identified areas for improvement. The NII were satisfied that improvements to command and control and manual muster arrangements were adequately demonstrated.
Compliance with Technical Specifications - focusing on boiler operation
Staff training, qualifications and experience
Modifications to plant equipment and safety cases - focusing on the installation of a new trip system to protect against water ingress to the reactor vessel.
Management of operations including control and supervision of the fuel route. As a result of this the station provided an improvement plan to reinforce standards and expectations on the fuel route

The site inspector attended the Outage Intentions meeting to review the scope of the forthcoming statutory outage on reactor 2 due in October 2009.

In general the arrangements made and implemented by the station in response to safety requirements were deemed to be adequate in the areas inspected. However, where improvements were considered necessary, satisfactory commitments to address the issues were made by or are being sought from the licensee, and the site inspector will monitor progress during future visits. Where necessary, formal regulatory enforcement action will be taken to ensure that appropriate remedial measures are implemented to reasonably practicable timescales.

Non-routine matters

Licensees are required to have arrangements to respond to non-routine matters and events. NII inspectors judge the adequacy of the licensee’s response including actions taken to implement any necessary improvements. There were no reportable events during the period.

Regulatory activity

Under Health and Safety legislation NII Site Inspectors, and other HSE Inspectors, may issue formal documents to ensure compliance with regulatory requirements. Under nuclear site licence conditions HSE/NII issues regulatory documents, which either permission an activity or requires some form of action to be taken; these are collectively termed Licence Instruments (LI). In addition inspectors may issue enforcement notices to secure improvements to safety.

Two Licence Instruments or enforcement notices were issued during the quarter:
Licence Instrument 532 giving our agreement to an extension of Hartlepool operating period for reactor 2 (deferral of the statutory outage)
Licence Instrument 533 gave our agreement to the replacement of neutron flux trip equipment

Changes to HSE's nuclear directorate

Government has decided to restructure HSE’s Nuclear Directorate (ND) to improve further its organisational framework for the sustained delivery of robust, effective and efficient nuclear regulation in the UK. This will place the ND in a better position to meet the anticipated future challenges.

Several factors have come together to make now the right time to restructure ND and create a new independent Nuclear Statutory Corporation (NSC) under the auspices of HSE. These include changing requirements of ageing nuclear power reactors; on-going decommissioning and active management of legacy nuclear plants; assessment of potential new nuclear power stations; growing competitiveness in the global nuclear skills market and the need for improved regulation driven by increased expectation from society for better accountability, transparency and efficiency from public sector bodies.

In addition to this was the government-initiated exercise conducted by Dr Tim Stone which examined the UK’s nuclear safety regulatory regime and identified a number of recommendations for improvement, including the need for structural changes to ND. The Summary Recommendations and the Government’s response were published at the end of January 2009 (available on HSE’s website).

HSE is working on the legislative measure that needs to be in place to create the NSC. These changes will be made through a Legislative Reform Order (LRO) under the Legislative and Regulatory Reform Act 2006.

Informing this, a joint consultation exercise was carried out by DECC and DWP that sought views on the proposed changes. The 12-week consultation period ended on 22 September 2009 and submissions are currently being assessed.

These new arrangements will not change the substance or standards of regulation or compromise the independence of the nuclear regulatory body, and will not affect the decisions it takes or the international obligations the Government requires it to meet.

These reforms are designed to lead to improvements in the transparency, accountability and consistency of regulatory activities, thereby seeking to enhance the confidence of all stakeholders, both duty holders and those with wider interests. The reforms would be expected to offer clear and direct benefits to industry and workers as well as society as a whole, which would benefit from efficient and continued robust and effective regulation of nuclear hazards.

Subject to the outcome of the consultation and Parliamentary approval, and if the Parliamentary timetable permits, the aim is to bring the new body into being during 2010.

An internal change programme is currently operating within ND to ensure that the ND is ready to operate when permitted by Parliamentary approval as a statutory corporation from spring 2010. This programme has identified key areas of action and deliverables, which will sit alongside the current business improvement programme and will ensure that operational business improvements are delivered alongside the set up of the new corporation.

It is important to recognise that this programme does not in anyway compromise the current business activity that is delivered through ND and strives to improve operational effectiveness and stakeholder engagement.